This privacy policy ("Privacy Policy") describes how SIMONE PERELE, S.A.S., a public limited company with a capital of 1,000.000 €, registered with the Nanterre Trade and Companies Register n° B622 041 713 713 and n° Siret 622 041 713 00117, whose registered office is located at 1, rue de Stockholm – 75008 Paris, as well as its subsidiaries in France and the European Union and its affiliated partners operating the Simone Pérèle brand (hereinafter referred to together as "SIMONE PERELE" or "WE"), use your personal data.

It applies as soon as SIMONE PERELE processes personal data concerning you, in particular during a visit to one of our points of sale under the Simone Pérèle brand or during your browsing on one of our commercial sites, in particular the one accessible at the address "https://www.simone-perele.com". (hereinafter collectively the "Site").

The list of Sites is at the top of the page.

This privacy policy aims to explain to you in a transparent manner how SIMONE PERELE collects and processes your personal data in accordance with the requirements of Act No. 78-17 of 6 January 1978 on data processing, data files and individual liberties, as amended, and European Regulation 2016/679 of 27 April 2016 (hereinafter referred to together as "the Regulation").

Within the meaning of the regulations, personal data refers to any information that directly or indirectly, alone or through a cross-reference with other information, makes it possible to identify a natural person (hereinafter referred to as "Data").

All entities of the SIMONE PERELE group are likely to process Data concerning you.

We inform you that SIMONE PERELE operates in particular according to a network model of its own and in affiliation. In other words, certain points of sale under our Simone Pérèle brand are operated by independent retailers who have been authorised to operate our brand and brands (Simone Pérèle/Implicite) (hereinafter "Partner").

In order to ensure the confidentiality and security of your data, all entities, including our Partners, have undertaken to treat your data in a harmonised manner under the conditions set out in this Privacy Policy.

When your data are collected by means of a questionnaire/form, the controller is the one who will have been identified in the information mention on the questionnaire/form.

When your data is collected via the Site, the controller is the publisher of the Site.

When your Data is collected during your visit to the store, the controller is SIMONE PERELE RETAIL SAS, alone or, if necessary, jointly with one of our Partners.

Your personal data is collected in the following two ways:

• Directly to you, when you freely communicate your personal data to us, i.e. during an active process on your part, on the Site or in one of our own stores or that of a Partner, for example when you register and/or create a personal account and/or place an order or purchase in stores and/or register for one of our services (newsletters, loyalty programme, etc.);
• Indirectly and automatically via your browsing traces on our Site (2).

We may also combine the data we collect when you visit a point of sale with data we collect on the Site if you are also a user of the Site.

Direct collection of your data

We collect personal data directly from you when you complete one of our forms on the Site or when you provide us with your data when you visit one of our sales outlets.

The mandatory or optional nature of the data is indicated to you at the time of collection by an asterisk on the form.

If your data is collected orally by a sales consultant, for example, the latter will inform you in advance whether the information requested is mandatory or optional.

Thus, the personal data collected directly from you, in particular may include the following personal data:

• your civility, your name, surname, first name;
• your Name(s)/First name(s);
• your postal address for delivery and invoicing;
• your email address;
• your telephone number;
• your date of birth;
• your height (top and bottom);
• your data relating to your means of payment (in particular the cardholder, the card number and validity date, visual cryptogram, the latter not being kept);
• your data related to your preferences (your product and service preferences);
• information relating to the follow-up of the commercial relationship (details of the products purchased, quantities, amounts, payment methods, any discounts granted);
• information relating to participation in competitions and/or any promotional operations (date, frequency, responses to competitions, prizes awarded);
• IP addresses when browsing the Website

Indirect collection of your data

We also collect certain data automatically and indirectly when you browse the Site.

The information collected automatically includes

• Information relating to your use of the Site such as pages viewed, time and duration of connection, IP address, connection method, such as type and version of your web browser, country, language, and service provider. This Data is only used to display a customized and relevant version of the Site. They are neither kept nor reused afterwards;
• Information about your equipment such as your operating system, mobile or tablet OS, as well as the unique device identifier ("UDID") and other technical identifiers;
  When ordering a product on the Site, the banking service provider with whom SIMONE PERELE has concluded contractual agreements collects and also processes Data concerning your means of payment (credit card number, expiry date of the credit card, visual cryptogram, the latter not being kept, etc.).The payment processes are secure.
  The Bank Data that may be transmitted to the Site does not allow it to carry out banking transactions.

We may use and disclose this data for the purposes identified in the article "Why do we use your data (purposes)? "of this Privacy Policy and this within the limits of applicable regulations.

We inform you that we may associate and combine all of this Data with each other in order to determine information concerning you and allowing us to get to know you better, such as your purchasing habits, your online behaviour, your preferences, etc., said associated information will then be treated by SIMONE PERELE as personal data within the meaning of Law No. 78-17 of 6 January 1978 on data processing, files and freedoms and European Regulation 2016/679 of 27 April 2016 (hereinafter referred to together as the "Regulations").

Cookies and web beacons

As part of the improvement of our services, cookies are set when you browse the Site.

In general, a "cookie" is a small text file stored in a dedicated space on the terminal's hard drive (e.g., computer, tablet, smartphone, etc.) of a media user (Internet, applications, etc.), when viewing content or advertising online and which records information related to your browsing from that device.

For all information concerning the use of cookies, please read the article "Specific provisions applicable to cookies" below.

Some web pages of the Site may contain web beacons to count the number of visitors to the Site and/or to provide us with a number of indicators. These web beacons may be used by some of the Company's subcontractors, in particular to measure and improve the effectiveness of the Site. In any event, the information obtained from these tags is used solely to gather statistics on the use of certain pages of the Site in order to better serve you.

The data processing operations that we carry out have as their legal basis:

• the execution of a contract between Simone Pérèle and you in the context of customer relations and the management and execution of an online order on the Site or a purchase in shops, including the management and follow-up of unpaid invoices and disputes or when you participate in competitions.
• or your consent to the sending of our newsletters as part of the loyalty programme or outside this programme (commercial newsletters).
• or on the basis of our legitimate interests for the security of the Site and in particular the security of online payments and the fight against fraud.

Managing and executing your orders

The information and data concerning you are necessary for the management of your orders and for our commercial relations, in particular to execute your payment, deliver you, draw up your invoice and ensure your guarantee as well as to ensure after-sales service.

This information and data are also stored in order to comply with our legal and regulatory obligations, particularly our accounting and tax obligations.

Managing your registrations

Your data is also necessary for us to manage your registrations on the Site and your personal space. (for example, your registration for an online account, newsletters, your membership in our loyalty program).

Knowing you and staying in touch with you

We use your data for communication purposes, in particular to respond to your requests, in particular via the online section "contact us", send you our news and keep you informed of our offers and the advantages you can enjoy.

We may also use your information to get to know you better, for example by analyzing your order history and/or online browsing history on the Site to send you targeted advertising.

To this end, we can:

• Or carry out individual solicitation procedures (for example, solicit you for products that are likely to interest you because you have consulted them and placed them in your shopping cart without validating the purchase);
• Either establish user profiles based on your browsing and purchasing behavior and send you advertisements likely to interest you because they concern products of interest to other customers or prospects with the same profile as yours in terms of browsing and online behavior.

This use of your data is only made with your consent, which you can withdraw at any time.

Improve / customize our products and services

We also use your data to improve our products and services.

To this end, we may solicit you by means of surveys and satisfaction questionnaires by email, telephone or telephone call.

Organize competitions

We may use your Data for the purpose of organizing contests in which you have registered.

Perform statistics

Finally, we use your information and data for statistical analysis purposes.

Fighting fraud

Some automatic or manual processing operations are aimed at verifying your online payments and combating payment fraud and identity theft (see" b) Cookies to secure payments

Your personal data are exclusively intended for SIMONE PERELE.

May, within the limits of their respective powers, have access to your personal data:

• persons in charge of marketing, sales, customer relations and prospecting, administrative services, logistics and IT services and their line managers;
• persons in charge of marketing, sales, customer relations and prospecting, administrative services, logistics and IT services and their line managers;
• our subcontractors, in particular those responsible for the execution of orders and, in general, our data hosting providers.
• the competent authorities who would make a request for it under the applicable legislation.

SIMONE PÉRÈLE is particularly committed to respecting your privacy and complying with regulations on the protection of personal data.

For this purpose, we only process your data for the strict duration necessary.

• In the context of the management and execution of your orders, your data is kept for the entire period of our commercial relationship, in particular until the expiry of your legal guarantee. Beyond that, your data is archived and kept until the applicable limitation periods expire.
• As part of managing your registration for our online services, we keep your data for the duration of your registration. Thus any unsubscribe request from you will result in the deletion of the data associated with your registration.

However, we inform you that any account that has been inactive for an uninterrupted period of two years will be considered inactive. At the end of this period, the data relating to your inactive Account will be deleted. We will notify you by any means before proceeding with such deletion in order to allow you to express your contrary intention

• As part of the use of your data when you subscribe to our newsletters and newsletters, we keep your data until you unsubscribe. We remind you that you have the possibility to unsubscribe from our communications at any time through the unsubscribe link contained in all our electronic communications.
• As part of your membership in a loyalty program, we keep your data for the entire period of membership in the program.
• As part of a registration for a contest, your Data is no longer stored beyond the game period, unless you are the winner. In this case, we may keep your Data until the delivery of your batch.
• As part of our targeted advertising operations, your data is stored for a period not exceeding 3 years from the last contact between you and us, unless you expressly authorize us to keep it and continue to process it beyond this 3-year period or, on the contrary, whether you have informed us that you do not wish to receive any further advertising from us.

As part of our statistics, we keep your data for the strict period during which the data must be aggregated. Once aggregated, your data is anonymized.

Beyond these retention periods, we may archive the Data for evidential purposes only and in strict compliance with the terms of legal requirements.

Cookies published by SIMONE PERELE

Cookies strictly necessary

a) Technical Cookies

Some of our cookies are exclusively intended to enable or facilitate the technical operation of our Site or online services and are strictly necessary for their provision.

These cookies therefore allow you to access the Site, ensure its security and memorize your browsing actions on the Site (select a product, consult the previous page, maintain your shopping cart etc,)

These are mainly session cookies - which are temporary and deleted when you close your browser - allowing authentication and connection to the Site as well as the storage of navigation elements during a session.

We also use "shopping cart" cookies to keep track of the items you have placed in the shopping cart during the same shopping session.

If you make the manual choice to delete or block the installation of these cookies, we inform you that some features of our Site may not work as intended and your access and use of the Site may be limited or impossible.

Thus, you are informed that deleting and blocking these cookies can seriously affect or even corrupt the online ordering process.

b) Cookies to secure payments

Cookies to secure online payments prevent payment fraud.

As such, SIMONE PERELE or its service providers acting on its behalf may, subject to your rights, deposit cookies and other tracers in order to collect information relating to the terminal that has made it possible to carry out online transactions (in particular the operating system used, the type of terminal, the use or not of proxy...).

These Cookies are intended to combat Internet fraud (prevention of fraud involving means of payment, identity theft, etc.).

These "fingerprint" type tracers associated with your online order data will be required by our system to validate your order, your payment method used and your delivery method. This information may be transmitted to any third party authorised by law or to the fraud prevention and detection service providers designated by SIMONE PERELE for the sole purpose of verifying your identity, the validity of the order, the payment method used and the planned delivery.

In any case, in addition to this information, you may be asked to provide proof of identity in order to validate your order in order to prevent any risk of fraud.

If you have any questions about these controls, please contact Customer Service.

Cookies that are not strictly necessary

a. Cookies for audience measurement

The cookies we use record information about your preferences and allow us to tailor them to your interests.

You have the possibility to define through your browser rules to accept all cookies, to be notified when a cookie is sent to you, or finally to define that you do not want to receive cookies.

The information provided by cookies may help us to better analyze your browsing on the Site.

We use these cookies to:

• Improve our products and services;
• To offer you targeted advertising;
• Measure our audience on the Site.

These cookies are only placed on your equipment with your consent.

The period of validity of your consent to the use of these cookies will not exceed thirteen (13) months.

In order to adapt our Site, its content and services to your expectations, we use the audience measurement service "Google Analytics". The cookies used as part of this service allow us to analyse the online behaviour of our Internet users and in particular the number of visits, the number of pages viewed as well as the activity on the Site and the return traffic.

In summary, these elements allow us to:

• establish statistics and volumes of visits and use of the various elements composing our Site (section and content visited, route) allowing us to improve the interest and ergonomics of our services;
• adapt the presentation of our Site or our advertising spaces to the display preferences of your device (language used, display resolution, operating system used, etc.) when you visit our Site, depending on the display or reading hardware and software that your device contains;
• detect navigation problems and therefore improve the ergonomics of our services.
• measure the effectiveness of our emailing campaigns, allowing us to take relevant commercial actions based on the information collected (for example, sending a new message or a personalized offer).

We inform you that the data generated by the cookies concerning the use of the website (including the IP address in short and unreadable form that does not allow the user to be identified) will be transmitted and stored by Google on servers that may be located in the United States.

Google will use this information for the purpose of evaluating the use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google's behalf. Google will not associate the IP address of Internet users with any other data held by Google.

You can choose to disable the use of cookies for statistical analysis of your browser data.

b. Advertising cookies

Advertising cookies allow SIMONE PÉRÈLE to analyse your preferences, in particular by memorising the products consulted and to display relevant and targeted advertising on your preferences on our Site or on one or more external sites. This may include, for example, advertising referring to our Site on products that you have viewed without finalizing or undertaking a purchasing process or products similar to those ordered or products generally purchased by other Internet users who have purchased products identical to yours.

The analysis of the data we collect through advertising cookies allows us to determine our advertising content according to your preferences and navigation.

In this context, we are led to:

• count the ads we display and analyze the performance of these ads (in particular via the number of clicks on these ads and the various actions taken on these ads);
• adapt the advertising content according to your navigation as well as the location data (longitude and latitude) transmitted by your terminal (subject to your prior agreement);
• to the extent that you have provided us with Data, including your electronic contact details, when you register, order or access one of our services, to associate such data with browsing information in order to send you, for example, electronic prospecting or to display on your terminal, within advertising spaces that we issue, personalised advertisements that are specifically intended for you that may be of personal interest;
• to establish user profiles (according to clicks, pages visited, products added to the shopping cart...) and send you electronic prospecting based on your user profile.

c. Sharing cookies

Sharing cookies allow us to insert, operate social network sharing buttons and evaluate and study your behavior. These sharing buttons allow you to:

• or to share the content of our Site via social networks;
• or to follow us on our social networks.

As such, the use of the sharing buttons available on our Site involves the placement of cookies on your equipment.

Currently, we have sharing links to Facebook, YouTube, Instagram and other similar social networks.

We may know and record the clicks you have made on these sharing buttons and, where applicable, certain public information from your accounts on these corporate networks (subject to your agreement).

Third-party cookies

Cookies are considered as third parties or owners depending on whether they are associated with the domain of the Site, i.e. whether they are published by the site editor (who controls these cookies) or published by a third party (without any control by the site editor).

We inform you that when you access the Site, one or more cookies from third parties may be placed in your equipment.

The purpose of these third-party cookies is to identify your interests through the products consulted or purchased on the Site and to collect browsing data in order to personalise the advertising offer addressed to you on and off the Site for products or services other than those we offer.

As such, we inform you that cookies issued by the following companies are stored when you access the Site:

• Youtube (due to the use of the youtube video player on our Site);
• Facebook (due to the use of the youtube video player on our Site);
• Google (due to our use of the Google Analytics service);
• Doubleclick (due to our partnership with the advertising agency Doubleclick, which specializes in behavioral targeting on the Internet).

We inform you that we have no access to and cannot exercise any control over these third-party cookies.

To learn more about these cookies, we invite you to consult the privacy and cookie policies and the general terms and conditions of use of these third party websites available here:

Facebook:  https://www.facebook.com/policies/cookies/

Youtube/ Google :

• https://policies.google.com/privacy?hl=en&gl=en 
• https://policies.google.com/technologies/cookies?hl=en

Whenever we collaborate with an advertising agency, we ensure that the use of your personal data and the deposit of cookies comply with applicable regulations by requesting and verifying, in particular, guarantees offered by our partners.

Your choices regarding cookies

You may choose at any time to disable all or part of the Cookies you have previously accepted.

You have different ways to manage your cookie choices:

1. Cookies management tools

SIMONE PERELE's cookie management tool allows you to understand and control the use of most of the cookies that the Site uses when you visit it and to adjust your preferences in this regard (refusal or acceptance)        

With regard to Advertising Cookies, you can also connect to the Youronlinechoices site, offered by digital advertising professionals grouped within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France. 

The refusal of these advertising cookies has no impact on the use of our site. However, refusing them will not result in the termination of advertising on our site or on the Internet.
This will only display an advertisement that does not take into account your interests. 

2. Cookies not managed by the SIMONE PÉRÈLE tool

Purpose EditorDisable linkAudience measurement Google Analytics : https://support.google.com/analytics/answer/181881?hl=en

Securing payment Adyen : https://www.adyen.com/policies-and-disclaimer/cookie-policy

3. The choices offered to you by your navigation software

You can also prevent the deposit of cookies or delete those already installed by modifying the settings of your browser; in such a case, you can proceed as follows:

• On Internet Explorer:

1. Go to Tools > Internet Options.
2. Click on the privacy tab.
3. Click on the advanced button, check the box "Ignore automatic cookie management".

• On Firefox:

1. At the top of the Firefox window, click on the Firefox button (Tools menu on Windows XP), then select Options.
2. Select the Privacy panel
3. Set Retention Rules: to use the custom settings for the history.
4. Uncheck Accept cookies.

• On Google Chrome :

1. Click on the Chrome menu icon.
2. Select Settings.
3. Click Show Advanced Settings.
4. In the "Privacy" section, click on Content Settings.
5. Select "Prohibit all sites from storing data".

For any question relating to this Privacy Policy or more generally relating to the processing of your personal data, SIMONE PERELE has appointed a Personal Data Protection Officer (hereinafter the "DPO"), one of whose tasks is to be your privileged contact.

The DPO's contact details can be reached at the following address:

Personal Data Protection Officer

62,rue d’Alsace – 92582 Clichy la Garenne cedex

privacy@simone-perele.fr.

In accordance with the French Data Protection Act (loi n°78-17) and Regulation n°2016/679 (Règlement Général sur la Protection des Données), you have the right to access, rectify and - in the event of a legitimate reason - oppose the processing of your personal data.

You also have a right to the limitation and portability of your data under the conditions provided for by the Regulations.

We remind you that, in accordance with the Regulations, your right to portability only applies to data that you have provided to us directly on the basis of your consent or the performance of a contract concluded with SIMONE PERELE. In addition, it only applies if your data are processed automatically (paper files are therefore not concerned).

Finally, you also have the right to define guidelines on the fate of your data after your death and to file a complaint with the CNIL (see www.cnil.fr for more information on your rights).

To exercise these rights or for any question about the processing of your data, you can contact the SIMONE PERELE DPO.

In accordance with the Regulations, to exercise your rights you must prove your identity.

If, after contacting us, you feel that your rights have not been respected, you can file a complaint with the CNIL.

We use a variety of data security measures to ensure the confidentiality and integrity of your personal information.

To this end, we inform you that:

• All SIMONE PERELE staff are aware of the protection and security of your personal data;
• Our Site is secure, in particular through the use of a TLS protocol;
• We make regular backups of data to prevent any risk of loss or damage;
• All interventions on our IT environment are secure;
• We have installed means of protection for our premises and servers;
• We have implemented a data access authorization policy so that only authorized persons can access your personal data.

Your personal data may be transferred to our subcontractors in a country outside the EU.

Concerned about the security and confidentiality of your data, we inform you that all our service providers are subject to an obligation of confidentiality and that all transfers are made to:

• Either a country recognised by the European Commission as ensuring an adequate level of protection
• Either an American company complying with the principles of the Privacy shield;
• Or to a country that does not offer adequate protection but whose transfer has been governed by the European Commission's standard contractual clauses, which the CNIL has previously recognised as guaranteeing an adequate level of protection of the private life and fundamental rights of individuals.

Whenever a transfer of your data outside the European Union takes place, we undertake to inform you:

• The quality of the recipient of your data;
• The country in which the recipient is located;
• Reasons why your data is transferred (for example, if you are hosting on remote servers);
• Legal guarantees that govern this transfer

To date, MAGENTO is our software solution provider for the design of our Site, which is hosted by Amazon Web.

These two service providers, qualified as subcontractors within the meaning of the regulations, are located within the European Union.

However, the data to which they have access, namely all the data collected and/or hosted on the Site, may be transferred outside the European Union, and in particular to servers located in the United States.

The purpose of data transfer is the corrective or evolutive maintenance of the Site and/or its hosting.

The following guarantees have been taken to ensure a sufficient level of protection of personal data: adherence to Privacy Shield.

This privacy policy may be modified at any time and at the free discretion of SIMONE PERELE.

If we change this privacy policy, we will publish the revised version here, with an updated revision date.

This Privacy Policy was last updated on March 28, 2019.

Concerned about the security and confidentiality of your data, we inform you that all our service providers are subject to an obligation of confidentiality and that all transfers are made to:

• Either a country recognised by the European Commission as ensuring an adequate level of protection;
• Either an American company complying with the principles of the Privacy shield;
• Or to a country that does not offer adequate protection but whose transfer has been governed by the European Commission's standard contractual clauses, which the CNIL has previously recognised as guaranteeing an adequate level of protection of the private life and fundamental rights of individuals.

Whenever a transfer of your data outside the European Union takes place, we undertake to inform you:

• The quality of the recipient of your data;
• The country in which the recipient is located;
• Reasons why your data is transferred (for example, if you are hosting on remote servers);
• Legal guarantees that govern this transfer.